Pilots
SMS Operations & Individual Responsibilities

Gold Aviation Services is a Part 135 on-demand air charter operator. Under 14 CFR Part 5, the FAA requires all Part 135 certificate holders to maintain an SMS. Our SMS is not just a compliance requirement; it is how we manage risk systematically, identify hazards before they become incidents, and continuously improve safety performance throughout our organization.

The SMS belongs to everyone in the organization.

Safety is a shared responsibility: every employee is expected to identify hazards, report safety concerns and all mandatory reportable events, and support the risk controls that keep our operation safe.

Key roles within the SMS:

• Accountable Executive (AE): Ultimate accountability for the SMS. Has authority over resources required to implement and maintain the system. Signs the safety policy [14 CFR §5.23, §5.25].
• Director of Safety (DOS): Day-to-day management of the SMS. Administers the voluntary reporting system, develops and tracks corrective actions through CAPA (Corrective Action / Preventive Action), conducts internal audits, facilitates external audits, administers the CASS program, maintains SMS records, the SDS/MSDS library, and safety training records.
• Director of Operations (DO) and Chief Pilot: Exercise operational control and oversee the integration of Operations department and Flight Operations department within the SMS.
• Director of Maintenance (DOM): Exercises operational control and oversees the integration of the Maintenance department within the SMS. Holds company authority for the maintenance program and ensures maintenance-related hazards are identified and addressed within the SMS.

• Safety Action Group (SAG): A cross-functional working group that executes review, analysis, and support tasks. Meets regularly to discuss hazards, learning outcomes, and policy changes while assessing risks and risk controls. The group reviews safety reports as needed and initiates action on identified issues.
• Safety Board: Chaired by the Accountable Executive. Meets quarterly to review safety performance data, SPI trends, audit results, and safety risk profile trends. Includes the Director of Safety, Director of Operations, Chief Pilot, Director of Maintenance, and leaders from other operating departments. Collaborates on organizational direction for safety priorities and resource allocation.

The Gold Aviation voluntary safety reporting system is the primary mechanism for hazard identification. Submit a report for any safety concern (hazard, near-miss, incident, operational error, equipment issue, or unsafe condition) at any time.

How to submit: Reports are primarily submitted through FOS. The Director of Safety is your point of contact for all safety reports.

What to report:

• Any hazard you observe (in operations, maintenance, facilities, processes or other areas).
• Any unplanned event that could have resulted in injury, damage, or loss
• Errors you made or observed that could recur or could be learned from
• Organizational conditions (pressure, fatigue, communication failures) that create safety risk

What happens after you report:

1. The Director of Safety receives your report through FOS (or directly if submitting report directly to the DOS).
2. The Director of Safety reviews the report and classifies the hazard and risk level.
3. The Director of Safety facilitates collaboration and risk assessment with appropriate Subject Matter Experts (SMEs) as needed.
4. If corrective action is required, a CAPA is opened, assigned, and tracked to closure.
5. The Director of Safety may contact you for additional information or follow-up. This is part of the process, not an investigation of you or your actions.
6. The system notifies you when the report is closed.

The Flight Risk Assessment Tool (FRAT) is Gold Aviation's Operational Risk Assessment: a mandatory pre-departure tool completed before every flight leg.

It applies binary scoring to defined risk factors across four categories: pilots, aircraft, environment, and external factors. Each factor is either present (1) or not applicable (0); the cumulative count determines overall risk level.

• Low risk: Operations may proceed. FRAT must be documented before departure.
• Medium risk: The DOS is notified and coordinates with the Chief Pilot before a go/no-go decision is made. Mitigations and the decision must be documented before departure.
• High risk: Do not depart. The DOS is notified and coordinates with the Chief Pilot on the go/no-go determination; a mitigation plan and crew briefing are required. Formal approval from the Accountable Executive is required prior to departure. All actions must be documented.

The FRAT is a core component of Gold Aviation's Safety Risk Management process.

Gold Aviation Services takes FRAT scores seriously. We have made, and will continue to make, operational adjustments to trips based on FRAT scores that fall outside the company's risk tolerance. Completing the FRAT honestly and accurately matters: your score can and does change what happens to a trip.

Just culture in flight operations means you can report honest mistakes, errors, near-misses, and hazards without fear of reprisal or discipline. It also means you are expected to use that protection responsibly: to surface safety information that helps the organization learn.

In practice, this means:

• If you make a mistake: report it. A self-reported error is handled very differently from a discovered unreported one.
• If you observe a colleague engaging in at-risk behavior: report it. The just culture framework applies to your report, not just your own conduct.
• If you feel pressure (from scheduling, dispatch, or management) that is causing you to take shortcuts: that is reportable. Organizational pressure is a systemic hazard.
• Removal from duty for fitness concerns including fatigue is a protected act. If you remove yourself from a flight for safety reasons, that decision is supported by Gold Aviation Services' Safety Policy.

As a pilot at Gold Aviation Services, your SMS responsibilities under 14 CFR Part 5 and the Gold Aviation SMS Manual include:

• FRAT completion: complete the Flight Risk Assessment Tool before every flight. Medium risk requires DOS notification and documented approval. High risk requires DOS notification and formal Accountable Executive approval before departure.
• Fitness to fly: you have a personal and regulatory obligation to assess your own fitness before every flight. Fatigue, illness, medication effects, and psychological stress are disqualifying if they impair your ability to perform your duties safely. I'M SAFE is a useful self-assessment tool.
• Hazard and incident reporting: submit a safety report for any hazard, incident, near-miss, unusual occurrence, any event type listed in Mandatory Reports or Voluntary Reports, or other safety-relevant event. Same-day reporting is strongly preferred.
• CRM and assertiveness: speak up. If you observe something concerning at any phase of flight, regardless of who is PIC, you are expected and empowered to raise it.
• Training: complete all assigned SMS training modules by the due date.

When a safety report, audit finding, or other identified hazard requires action, the DOS opens a CAPA in FOS. This is how Gold Aviation Services documents, assigns, tracks, and verifies the response to safety risks.

1. Initiation: DOS opens a CAPA, links it to the originating report or finding, and documents the hazard and risk level
2. Root Cause Analysis: root cause and contributing factors are identified and documented
3. Assignment: a specific, verifiable action is assigned to a responsible party with a due date
4. Implementation: the assigned party completes the action
5. Verification: DOS confirms the action was completed and effective
6. Closure: the CAPA is closed with any applicable documentation

If you are contacted by the DOS during the investigation phase, that is a normal part of the process. It is not an investigation of you personally and does not affect your just culture protections.

• The SMS is a shared responsibility, but you play a direct role in keeping it working: report what you see, complete your FRAT honestly, and speak up.
• A Medium or High FRAT score isn't a failure, it's the system working. High risk means you do not depart until the DOS is notified and a mitigation plan is in place.
• Good-faith reports are protected under just culture. A self-reported error is handled very differently from a discovered, unreported one.
• Corrective actions are how reports turn into real change, and every one has a due date and a responsible party.

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